Rights as a Unitholder. The Profits Interest Units shall be treated as a “profits interest” within the meaning of Revenue Procedure 93-27, and the Recipient shall be treated as having received the interest on the Grant Date as contemplated under Section 4 of Revenue Procedure 2001-43. As the owner of the Profits Interest Units for income tax purposes, the Recipient shall take into account the Recipient’s distributive share of income, gain, loss, deduction and credit associated with the Profits Interest Units as determined in accordance with the terms of the Limited Partnership Agreement and this Agreement.
Appears in 6 contracts
Samples: Profits Interest Units Agreement (OHI Healthcare Properties Limited Partnership), TSR Based Performance Profits Interest Units Agreement (OHI Healthcare Properties Limited Partnership), Profits Interest Units Agreement (OHI Healthcare Properties Limited Partnership)
